IEEPA refund equals the IEEPA-attributable portion of duty paid (typically 10% or 15% ad valorem of customs value depending on entry date) plus statutory interest from the date of payment to the date of refund. Section 232 and Section 301 portions are NOT refundable through CAPE. MPF and HMF are NOT refundable.
CAPE filings require accurate calculation of the IEEPA-attributable refund plus statutory interest. The math itself is straightforward; the documentation supporting each input is where filings succeed or fail.
This guide walks through three worked examples covering common entry types.
Example 1 – pure IEEPA (no Section 232 or 301 stacking)
Vietnam-origin apparel, entry date August 15, 2025, customs value $40,000.
IEEPA rate at that date: 10%. IEEPA portion of duty paid: $40,000 × 10% = $4,000.
Refundable amount: $4,000 plus statutory interest (IRS quarterly rate, currently ~7%) from August 15, 2025 to refund date.
For 12 months elapsed: ~$280 interest. Total refund: ~$4,280.
Example 2 – IEEPA with Section 232 steel stacking
Mexican-origin (non-USMCA-qualifying) steel article, entry date November 20, 2025, customs value $250,000.
IEEPA rate: 15%. Section 232 steel: 25%.
In this case, Section 232 governed and was paid; IEEPA was NOT applied (Section 232 in lieu). No IEEPA refund available.
If the entry filed paid both Section 232 AND IEEPA in error, the IEEPA portion ($37,500) is refundable. Confirm CBP Form 7501 box 35-37 breakdown.
Example 3 – IEEPA with Section 301 stacking
China-origin electronics, entry date October 1, 2025, customs value $100,000.
IEEPA rate: 15%. Section 301: 25%. Both applied.
IEEPA portion paid: $15,000. Section 301 portion: $25,000.
Only the IEEPA portion ($15,000) is refundable. Plus statutory interest from October 1, 2025.
Statutory interest calculation
Interest accrues from date of duty payment to date CBP issues the refund. Rate is the IRS quarterly underpayment rate (varies; typically 7-8% annualized in 2025-2026).
For each calendar quarter, calculate the daily rate × number of days × refund principal. Sum across all quarters from payment date to refund date.
CBP’s system performs the calculation; importer must claim interest explicitly in the filing.
Frequently asked questions
Are Section 232 and Section 301 duties refundable?
No. Only the IEEPA-attributable portion is refundable through CAPE. Section 232 and Section 301 remain owed.
How is interest calculated?
IRS quarterly rate × number of days × refund principal, summed across all quarters from payment date to refund date.
Can I file CAPE without claiming interest?
Yes, but you forfeit the interest. Always claim explicitly.
What if my entry summary does not break out IEEPA from other duty?
Pull the broker’s detailed line-item record. CBP’s ACE system retains the breakdown even if the summary reports a single duty figure.
Do partial refunds count?
Yes. CAPE may approve part of a claim and reject part. Approved portions are paid with interest; rejected portions can be re-filed with corrected documentation.
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